AML / Financial Crime

What Changed

Consolidation and repeal: Replaces outdated circulars with unified requirements under the amended Law of 10 November 2009 on payment services, covering central administration (decision-making must be in Luxembourg), management body responsibilities, internal control functions (compliance, risk management, internal audit as independent second/third lines), conflicts of interest management, new product approval processes, and client funds safeguarding (e.g., segregation, daily/weekly reconciliatio

What You Need To Do

• Assess and update governance frameworks
• Confirm control functions
• Implement operational safeguards
• Document proportionality
• Retain records and report

Key Dates

References

• [1] financialcrime.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] elvingerhoss.lu
• [5] cssf.lu
• [6] cssf.lu

What Changed

Amendment to Annex 2 of SR 946.231.12, updating the list of sanctioned individuals, entities, and organizations subject to financial restrictions. Integration into the SECO Sanctions Management (SESAM) database, with urgent publication on the SECO website. Reinforcement of prohibitions: asset freezing, ban on making funds available, and reporting of affected business relationships to SECO; does not exempt from GwG Art. 6 due diligence or Art. 9 suspicious activity reports. These align with ongoi

What You Need To Do

• Screen client portfolios and transactions against the updated SESAM database immediately upon effectiveness
• Freeze assets of newly listed sanctioned parties and prohibit making funds/resources available
• Report affected business relationships to SECO without delay
• Conduct GwG Art
• Monitor MyFINMA for FINMA alerts and update internal sanctions screening tools

Key Dates

References

• [1] gtai.de
• [2] finma.ch
• [3] finma.ch
• [4] finma.ch
• [5] mercury.ch
• [6] hubplus.ch
• [7] finma.ch
• [8] finma.ch

What Changed

The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela. While the search results reference a separate FINMA ordinance (RS 196.127.85) adopted on January 5, 2026, which froze assets of 37 persons in the context of Venezuela, the January 13 update to SR 946.231.178.5 represents an amendment to Switzerland's broader sanctions ordinance framework. The specific changes to Annex 1 require Swiss entities to: Update their sanctions

What You Need To Do

• *Immediate Screening
• *Asset Identification
• *Freeze Implementation
• *Notification
• *Transaction Review

Key Dates

References

• [1] finma.ch
• [2] k2integrity.com
• [3] ofac.treasury.gov
• [4] clearygottlieb.com
• [5] complyadvantage.com
• [6] hklaw.com
• [7] finma.ch
• [8] hsfkramer.com

What Changed

The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibit

What You Need To Do

• Block prohibited activities in energy sector, financial services (e
• Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11)
• Monitor FINMA's sanctions page for full ordinance text and related guidance

Key Dates

References

• [1] practiceguides.chambers.com
• [2] lenzstaehelin.com
• [3] finews.com
• [4] efd.admin.ch
• [5] finma.ch
• [6] finma.ch
• [7] sdc-cde.ch
• [8] investmentpolicy.unctad.org

What Changed

No new regulatory changes or requirements are introduced in this publication, as it is an enforcement notice rather than a circular or guideline. It serves as a disclosure of an ongoing or concluded enforcement case, aligning with CSSF's practice of publishing sanction details to deter non-compliance and inform the market, without altering existing rules. #

What You Need To Do

• For the named population
• For all supervised firms
• Update internal policies, train staff on enforcement precedents, and ensure robust reporting under Circular CSSF 19/726 or Transparency Law obligations

References

• [1] cssf.lu
• [2] aoshearman.com
• [3] pwc.lu
• [4] bakermckenzie.com
• [5] cssf.lu
• [6] cssf.lu
• [7] elvingerhoss.lu
• [8] ey.com

What Changed

This is not a regulatory change but an enforcement precedent under existing rules: non-compliance with Article 5(1) of the AML/CFT Law, which mandates annual submission of a financial crime questionnaire ("Questionnaire") to the CSSF. The fine was calculated per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), considering circumstances under Article 8-5(1). Publication followed Article 8-6(1) after a proportionality assessment, confirming no market stability risks. No new requirements were introduced;

What You Need To Do

• Immediately review internal processes for annual Questionnaire submission, ensuring calendar invites and automated reminders for the 4 April deadline (covering prior year-end data)
• Conduct a gap analysis on AML/CFT cooperation obligations under Article 5(1), including response protocols to CSSF reminders or queries
• Update compliance calendars and train staff on escalation procedures; document all submissions with proof (e
• If late, proactively submit overdue items and request meetings if needed, as non-response forfeits mitigation opportunities

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] seqlense.com
• [5] bsp.lu
• [6] cvc.com
• [7] gouvernement.lu
• [8] caceis.com

What Changed

This is not a regulatory change but rather an enforcement action clarifying existing obligations: Mandatory Annual Questionnaire Requirement: All professionals supervised, authorized, or registered by the CSSF must submit an annual questionnaire on financial crime by April 4 each year, covering the preceding calendar year. Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, which includes timely su

What You Need To Do

• regulated entities must
• *Establish Calendar Controls
• *Designate Responsible Parties
• *Prepare Documentation
• *Monitor Communications

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] seqlense.com
• [4] cssf.lu
• [5] cssf.lu
• [6] blogs.duanemorris.com
• [7] cssf.lu
• [8] cssf.lu

What Changed

This is not a regulatory change or new requirement but an enforcement precedent under existing rules: non-compliance with the annual financial crime questionnaire submission, mandated by Article 5(1) of the AML/CFT Law, triggers fines per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a). The CSSF considered all relevant circumstances under Article 8-5(1) to set the €10,000 fine amount and published the sanction nominatively after proportionality assessment per Article 8-6(1), confirming no market stabi

What You Need To Do

• Ensure timely submission of annual financial crime questionnaires by 4 April each year (for prior calendar year data); implement calendar reminders and escalation processes for CSSF requests
• Respond promptly to CSSF reminders or queries on AML/CFT compliance to avoid escalation to fines; document any delays with justification evidence
• No retroactive actions needed for this case, but conduct gap analysis on reporting workflows to prevent similar breaches

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] cssf.lu
• [5] regulatoryandcompliance.com
• [6] cssf.lu
• [7] sec.gov
• [8] pinsentmasons.com

What Changed

This is not a regulatory change but rather an enforcement action clarifying existing obligations. However, it reinforces critical compliance requirements: Mandatory Annual Questionnaire Submission: All CSSF-supervised professionals, including AIFMs, must submit an annual questionnaire on financial crime by the specified deadline (in this case, 4 April 2025 for the year ending 31 December 2024). Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on the fight against mon

What You Need To Do

• *Establish Calendar Controls
• *Designate Responsible Parties
• *Monitor CSSF Communications
• *Document Submission
• *Escalate Non-Compliance Immediately

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] opensanctions.org
• [5] boldergroup.com
• [6] bsp.lu
• [7] efama.org
• [8] pwc.lu

What Changed

This is not a regulatory change but rather an enforcement action clarifying existing obligations: Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year. Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests. Enforcement Escalation: The CSSF will issue reminders before imposin

What You Need To Do

• regulated entities must
• *Identify Reporting Obligations
• *Calendar Management
• *Documentation
• *Escalation Protocol

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] opensanctions.org
• [5] cliffordchance.com
• [6] elvingerhoss.lu
• [7] imf.org

What Changed

This is not a regulatory change but rather an enforcement action that clarifies existing obligations: Mandatory Annual Reporting: All CSSF-supervised professionals must submit an annual questionnaire on financial crime by 4 April each year, covering the preceding calendar year. Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, including timely submission of requested documentation. Enforcement Esc

What You Need To Do

• *Establish Reporting Calendars
• *Designate Responsible Personnel
• *Respond to Regulatory Requests
• *Document Justifications
• *Monitor Supervisory Communications

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] cssf.lu
• [5] opensanctions.org
• [6] sorainen.com
• [7] ubp.com
• [8] adaptation-fund.org

What Changed

This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing (AML/CFT Law). Specifically, it reaffirms the mandatory annual submission of the CSSF's financial crime questionnaire ("Questionnaire") by supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, as part of the cooperation duty in Article 5(1). The fine was cal

What You Need To Do

• Immediately verify submission status of the 2024 Questionnaire (or any outstanding); if overdue, submit promptly with justification to mitigate further escalation
• Implement automated calendar alerts and internal workflows for all CSSF reporting deadlines, including annual AML/CFT Questionnaire
• Conduct a compliance gap analysis on cooperation obligations under Article 5(1) AML/CFT Law, documenting reminder responses and evidence retention
• Train senior managers and compliance teams on supervisory interactions, including rights to request in-person meetings before fines
• Review governance for timely escalation of CSSF reminders to decision-makers

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] cssf.lu
• [5] fi.se
• [6] cssf.lu
• [7] africagrowthfund.org
• [8] funds-europe.com

What Changed

This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law: Annual Questionnaire Submission: Supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, must submit an annual financial crime questionnaire ("Questionnaire") to CSSF as part of the cooperation duty in Article 5(1). Fine Provisions: Fines are imposed per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), with amounts determined by relevant

What You Need To Do

• Immediate Review
• Remediation if Late
• Process Enhancements

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] cssf.lu
• [5] blogs.duanemorris.com
• [6] opensanctions.org
• [7] cssf.lu
• [8] misp-project.org

What Changed

This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law: Article 5(1) mandates supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, to cooperate fully with CSSF, including submitting the annual financial crime questionnaire ("Questionnaire"). Breach occurred due to non-submission of the 2024 year-end Questionnaire, with fine determined per Articles 8-4(1), 8-4(2)(f), 8-4(3)(a), and 8-

What You Need To Do

• Review and confirm timely submission of all pending or future CSSF financial crime questionnaires; establish automated calendar reminders for annual deadlines (e
• Implement escalation protocols for CSSF reminders, ensuring immediate response and submission within days, not weeks
• Conduct internal audit of AML/CFT cooperation obligations, documenting justifications for any delays and preparing evidence for potential CSSF hearings or meetings
• Update compliance policies to prioritize Article 5(1) duties, including training for responsible persons on fine risks under Article 8-4

Key Dates

References

• [1] cssf.lu
• [2] cssf.lu
• [3] cssf.lu
• [4] cssf.lu
• [5] blogs.duanemorris.com
• [6] cssf.lu
• [7] cssf.lu
• [8] cssf.lu

What Changed

This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures. Key breaches highlighted include: Imprecise investment allocation processes lacking traceability, rendering systems non-operational. Failure to fulfill conflict of interest identification, prevention, and management obligations. Deficient AML/CFT systems with inadequate due diligence on fund assets/lia

What You Need To Do

• Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules
• Enhance AML/CFT systems
• Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously
• Senior managers
• Audit marketing materials, fee retrocessions, and valuation procedures (e

Key Dates

References

• [1] amf-france.org
• [2] amf-france.org
• [3] amf-france.org
• [4] amf-france.org
• [5] amf-france.org
• [6] solutions-atlantic.com
• [7] amf-france.org
• [8] amf-france.org

What Changed

Revised LFR Structure: Comprises four parts in a single digital document: (1) yearly SAQ completed by investment firms; (2) descriptive elements verified by approved statutory auditors (REAs); (3) AML/CFT report with risk assessments, declarations on audits, and data on incomplete fund transfers; (4) REA's independent assessment of ML/FT risks and organizational aspects. Digital Format: Completion and submission via CSSF's online portal, supporting CSSF 4.0 digital strategy for efficient process

What You Need To Do

• Investment Firms
• REAs/Auditors

Key Dates

References

• [1] cssf.lu
• [2] bakermckenzie.com
• [3] cssf.lu
• [4] cssf.lu
• [5] cssf.lu
• [6] cssf.lu
• [7] cliffordchance.com
• [8] ogier.com

What Changed

Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously sanctioned under the Embargo Act. Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA provisions. Duration: The freeze is valid for four years until 4 January

What You Need To Do

• Screen and identify
• Freeze assets
• Report to MROS
• Internal updates
• Document compliance

Key Dates

References

• [1] finma.ch
• [2] news.admin.ch
• [3] sanctionsnews.bakermckenzie.com
• [4] clearytradewatch.com
• [5] euronews.com
• [6] finma.ch

What Changed

This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including: Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints. Formalized due diligence prior to allocating investment projects to funds. No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completenes

What You Need To Do

• Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e
• Document all processes rigorously
• Conduct gap analysis against AMF expectations
• Senior manager training
• Appeal monitoring

Key Dates

References

• [1] amf-france.org
• [2] amf-france.org
• [3] amf-france.org
• [4] amf-france.org
• [5] amf-france.org
• [6] amf-france.org
• [7] amf-france.org
• [8] amf-france.org

What Changed

The total revision introduces several critical regulatory shifts: *Scope Expansion**: The revised ordinance restores seven previously suspended UN Security Council resolutions (1696, 1737, 1747, 1803, 1835, 1929, and 2224) and aligns Swiss sanctions with EU measures reactivated on September 29, 2025. *Sectoral Restrictions**: New measures in the raw materials sector have been introduced, complementing existing prohibitions on: Sale or supply of key energy sector equipment Gold, precious metals

What You Need To Do

• *Immediate (Completed by December 12, 2025)
• related transactions and accounts for compliance with expanded prohibitions
• *Short-term (By January 1, 2026)
• September 30, 2025 contracts under legacy exemption provisions
• related transactions

Key Dates

References

• [1] finma.ch
• [2] news.admin.ch
• [3] efd.admin.ch
• [4] finma.ch
• [5] ihk.de
• [6] wko.at
• [7] finma.ch
• [8] finma.ch

What Changed

Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists. Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans. Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector. Fi

What You Need To Do

• Immediate screening
• Asset freezing
• Transaction halts
• Ongoing monitoring

Key Dates

References

• [1] finma.ch
• [2] bmwet.gv.at
• [3] finma.ch
• [4] finma.ch
• [5] vbw-bayern.de
• [6] seco.admin.ch
• [7] finma.ch
• [8] finma.ch

What Changed

The UN Sanctions Committee modified the sanctions list targeting persons, companies, and organizations related to Iraq on December 9, 2025; this amendment was published by SECO on its website and integrated into the SESAM sanctions database on December 10, 2025. Switzerland automatically applies UN sanctions lists without delay per the Federal Council's Ordinance of March 4, 2016, making the update immediately binding. Financial intermediaries must implement prohibitions, freeze assets of newly

What You Need To Do

• Screen against SESAM database
• Asset freeze
• Report to SECO
• Internal review
• Document compliance

Key Dates

References

• [1] bafu.admin.ch
• [2] finintegrity.org
• [3] finma.ch
• [4] finma.ch
• [5] finma.ch
• [6] ofac.treasury.gov
• [7] bakermckenzie.com
• [8] info4c.net

What Changed

The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries. The timing of this update aligns with broader international sanctions activity on Sudan. In July 2025,

What You Need To Do

• *Sanctions List Update
• *System Screening
• *Transaction Review
• *Blocked Assets
• *Staff Training

Key Dates

References

• [1] steptoe.com
• [2] finintegrity.org
• [3] ofac.treasury.gov
• [4] finma.ch
• [5] press.un.org
• [6] gov.im
• [7] finma.ch
• [8] finma.ch

What Changed

This is an enforcement action, not a regulatory change, but it clarifies and strengthens application of existing AMF rules for conseillers en investissements financiers (CIFs) under French regulations: Mandatory compliant documentation (e.g., investment proposals). Obligation to act honestly, fairly, and professionally in clients' best interests, including systems to prevent managers exploiting positions for undocumented investments. AML/CFT compliance, including prohibitions on directors receiv

What You Need To Do

• Audit documentation
• Strengthen governance
• Enhance AML/CFT
• Improve inspection readiness
• Senior manager reviews

Key Dates

References

• [1] amf-france.org
• [2] amf-france.org
• [3] steel-eye.com
• [4] amf-france.org
• [5] amf-france.org
• [6] amf-france.org
• [7] amf-france.org
• [8] amf-france.org

What Changed

This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime. Key breaches included: misconfigured monitoring systems missing 30,442,437 transactions (31% of activity over 12 months); delayed r

What You Need To Do

• Conduct Gap Analysis
• Enhance Controls
• Accelerate STR Processes
• Board/Compliance Reporting
• Third-Party Review

Key Dates

References

• [1] wp.nyu.edu
• [2] centralbank.ie
• [3] flagright.com
• [4] centralbank.ie
• [5] centralbank.ie
• [6] pinsentmasons.com
• [7] vinciworks.com
• [8] coinbase.com

What Changed

Introduces new modules in the revised SAQ to align with supervisory points of focus, building on prior expansions (e.g., credit/counterparty risk, liquidity risk, climate-related risks from CSSF 23/845). Emphasizes REA's independent assessment in the AML/CFT report, requiring exhaustive, transparent evaluations of ML/FT risks across institutions, branches, majority-owned subsidiaries abroad, and tied agents; prohibits vague language (e.g., no "no serious weaknesses" phrasing) and mandates positi

What You Need To Do

• Complete and submit revised SAQ annually, incorporating new modules on supervisory focuses like ML/FT risks and providing detailed data to REA
• Authorized management
• Ensure AML/CFT report details methodologies (e
• Review prior LFR submissions against this update to align with suppressed redundancies and new emphases

Key Dates

References

• [1] cssf.lu
• [2] dlapiper.com
• [3] cssf.lu
• [4] ogier.com
• [5] cssf.lu
• [6] stradalex.lu
• [7] cssf.lu
• [8] cssf.lu

What Changed

The circular introduces a three-component reporting framework that fundamentally alters the compliance landscape: Self-Assessment Questionnaire (SAQ): A digital, annually-completed questionnaire that institutions must prepare directly, covering domains within CSSF and ECB prudential supervision competence Agreed Upon Procedures (AUP) Reports: Reports prepared by approved statutory auditors (réviseurs d'entreprises agréés) on specific compliance areas Separate REA Report on Financial Instruments

What You Need To Do

• *For Credit Institutions
• *Establish SAQ Governance
• *Data Preparation
• *Digital System Access
• *Module Completion

Key Dates

References

• [1] cssf.lu
• [2] pwc.lu
• [3] cssf.lu
• [4] cssf.lu
• [5] cssf.lu
• [6] dlapiper.com
• [7] stradalex.lu
• [8] cssf.lu

What Changed

Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine. Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening), financial services (e.g., transaction bans on additional banks), and energy sectors. Requirements for financial intermediaries to

What You Need To Do

• Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists)
• Freeze assets of newly sanctioned persons/entities and prohibit dealings (e
• Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist
• Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e
• Review third-party exposures (e

Key Dates

References

• [1] finma.ch
• [2] belarus.ahk.de
• [3] finma.ch
• [4] finma.ch
• [5] vbw-bayern.de
• [6] finma.ch
• [7] bafa.de
• [8] wbf.admin.ch

What Changed

*Financial Sector Restrictions** The Bundesrat expanded transaction prohibitions on Russian banks substantially: Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions Introduced new transaction prohibitions for 22 additional Russian banks Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previou

What You Need To Do

• *Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
• *Freeze assets of all sanctioned persons and entities immediately upon notice
• *Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
• *Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
• *Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy

Key Dates

References

• [1] finma.ch
• [2] finma.ch
• [3] bundesregierung.de
• [4] finma.ch
• [5] noerr.com
• [6] finma.ch
• [7] finma.ch
• [8] finma.ch

What Changed

Amendment to the Annex of the Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti, incorporating UN Security Council updates to the sanctions list, likely adding individuals, companies, or organizations subject to asset freezes, travel bans, and arms embargo expansions. Reflects broader UN measures, including renewal of travel bans, asset freezes, and arms embargoes; expansion of arms embargo scope to military goods, technology, technical assistance, financial services, and brokeri

What You Need To Do

• Screening and Freezing
• Ongoing Monitoring
• Licensing Checks
• Documentation

Key Dates

References

• [1] legislation.gov.uk
• [2] gov.je
• [3] legislationtracker.co.uk
• [4] drs.customs.gov.hk
• [5] fscmontserrat.org
• [6] securitycouncilreport.org
• [7] finma.ch
• [8] international.gc.ca

What Changed

Modification of entries for two individuals in the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5), likely involving updates to personal details, aliases, or sanction rationales. These changes align with ongoing maintenance of the sanctions list, originally imposed in June 2020 due to human rights, democracy, and rule-of-law concerns in Nicaragua, mirroring EU measures from 2019-2020. No broader structural changes to the ordinance itself; this is a targeted annex update,

What You Need To Do

• Immediate screening
• Block and report
• Update compliance systems
• Monitor ongoing
• Document implementation to demonstrate due diligence in case of FINMA audits

Key Dates

References

• [1] mission-eu-bruessel.eda.admin.ch
• [2] finma.ch
• [3] seco.admin.ch
• [4] seco.admin.ch
• [5] finma.ch
• [6] finma.ch
• [7] finma.ch
• [8] finma.ch

What Changed

The core change is the WBF's amendment to the SESAM (SECO Sanctions Management) database, updating the list of sanctioned persons, companies, and organizations related to Iran sanctions. This aligns with the Swiss Iran Ordinance and reflects broader international reimposition of UN sanctions via the JCPOA snapback mechanism triggered in late September 2025. No new Swiss-specific requirements are introduced beyond standard implementation of the updated list, but it emphasizes urgent publication a

What You Need To Do

• Immediate screening
• Asset freeze
• Transaction blocks and reporting
• Due diligence enhancement
• Internal controls

Key Dates

References

• [1] mrllp.com
• [2] finintegrity.org
• [3] sanctionsnews.bakermckenzie.com
• [4] steptoe.com
• [5] fscmontserrat.org
• [6] mayerbrown.com
• [7] finma.ch
• [8] ofac.treasury.gov

What Changed

Modification to the list of sanctioned individuals, enterprises, and organizations under the Burundi sanctions ordinance. Update published in the SECO Sanctions Management (SESAM) database, which is the authoritative Swiss reference for sanctions compliance. No details on specific additions, deletions, or alterations to designations are provided in the publication summary, but changes trigger mandatory screening and blocking obligations. #

What You Need To Do

• Screen clients, transactions, and assets against the updated SESAM database immediately upon effectiveness (post-8 October 2025, 23:00)
• Freeze assets of newly listed or modified sanctioned parties without prior notice and report to SECO/FINMA via MyFINMA notification system
• Cease any direct or indirect provision of funds/economic resources to sanctioned parties; conduct retrospective reviews of existing relationships for Burundi exposure
• Update internal sanctions screening tools, policies, and staff training to reflect SESAM changes; document compliance efforts for potential FINMA audits

Key Dates

References

• [1] cgc.org.cy
• [2] globalsanctions.com
• [3] finma.ch
• [4] sdc-migration.ch
• [5] bag.admin.ch
• [6] swlegal.com
• [7] 2021-2025.state.gov
• [8] finma.ch